The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts. less -

While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review....more

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case...more

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

On June 18, 2014, the Internal Revenue Service (IRS) announced major changes to its 2012 Offshore Voluntary Disclosure Program (OVDP) and streamlined procedures. The modifications provide new options to help both taxpayers...more

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

The Department of Justice has had enough. Banks and other financial institutions are not just on the radar screen – they are on the chopping block. One-by-one watch out – banks and other financial institutions are coming...more

On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more

The Internal Revenue Service (IRS) recently announced in Notice 2014-33 that 2014 and 2015 will be transitional years from an administrative and enforcement perspective regarding the implementation of the Foreign Account Tax...more

Recent comments by Andrew Bowden, Director of the Office of Compliance Inspections and Examinations for the Securities and Exchange Commission (SEC), highlight the growing tension between Dodd-Frank compliance and fund...more

The Internal Revenue Service Large Business and International Division (LB&I) administers United States tax law for corporations, partnerships and individuals with assets greater than $10 million. These taxpayers typically...more

The U.S. information reporting and withholding tax regime known as "FATCA"[1] was signed into law on March 18, 2010. In the nearly four years since, the attention of international financial institutions of every variety,...more

Continuing our Sherlock Holmes homage, today we draw inspiration from the character of Inspector Lestrade as the theme of this blog post.
I thought about Inspector Lestrade when I read some of the comments of UBS Chief...more

Protecting domestic revenue is just one of several reasons why G-20 nations are cracking down on tax havens. Other reasons include their desire to track the international flow of funds used for terrorist activity or money...more

In This Issue:
- Summary Of FCRA Obligations On Employers That Use Consumer Reports For Employment Purposes
- Potential Liability For FCRA Non-Compliance And The Growing Wave Of FCRA Class Action
-...more

The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more

SEC and EU Supervisory Cooperation for Asset Management Industry -
On July 19, the SEC announced that it signed various memoranda of understanding with the financial regulators of 25 member states of the EU and 3...more

This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more

U.S. Funds with Only U.S. Investors -
FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

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